| Comment Number: | OL-10508035 |
| Received: | 3/14/2005 5:02:14 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| No Attachments |
Comments:
While the verbage in the NSPS regulations make this sound like an improvement over the current GS schedule, I believe it has several fatal flaws. For one thing, the need for a flexible workforce may apply to a small percentage of DoD positions, but I believe the majority of GS workers perform ongoing sustainment functions whose main contribution is stability and institutional knowledge. There is no reason to subject these folks to a radical change in the personnel system. Secondly, this system negates many of the protections workers have aganinst favoritism in hiring and pay. Pay banding and salary levels will be based on subjective criteria used by supervisors. This could easily lead to abuses. In addition, it causes substantial uncertainty to employees as to their income, not only in their current job, but when they are contemplating applying for other civil service positions. Conversely, the NSPS system will impose an even heavier administrative burden on supervisors to justify performance appraisals, performance "shares" and monetary awards. The vast majority of DoD supervisors are "working" supervisors, meaning they have other daily responsibilites/functions aside from supervising employees. The added time required to properly administer this system while trying to respond to the ever increasing demands of the Global War on Terrorism willl make an untenable situation for first-line supervisors. I expect that if NSPS is adopted, many experienced GS employees will retire rather than submit to the change. That will cause a severe "brain drain" on DoD at a time when it can ill afford it. While I agree with rewarding high performing employees, the current system already provides means to do that. I don't see a need to overhaul the entire system just to provide more flexibility in certain critical areas. Overall, this proposal strikes me as a slap in the face to the current DoD employees who have worked their hearts out in support of this nation and I don't see any benefits. NSPS undercuts years of protections against cronyism and favoritism that have been incorporated into our current system. The GS system may need some tweeking to make it more responsive, but NSPS goes too far. I totally oppose this proposal